Facts
The Islamic Dawah Council of the Ph (IDCP), a local federation of 70 Muslim organizations, filed a class suit in behalf of Muslim members nationwide against MVRS Publications et al in RTC Manila.
The complaint arose from an article in Bulgar in August of 1992 stating that the reason why Muslims don’t eat pork is that they worship it.
IDCP alleged that it was insulting, ignorant, and intended to hurt the feelings, of not just Muslims in the Philippines but in the whole world.
MVRS et al’s defense is that it did not mention respondents as the object of the article, it’s merely an opinion, and published without malice or injury.
RTC dismissed the complaint. Reason: the Muslims failed to establish their cause since the persons were not specifically identified.
CA reversed RTC: Article clearly defamed all adherents of the Islamic faith. MVRS appealed to SC
Issue
Does the Islamic Dawah Council of the Ph have a cause of action or is a property party to this case?
Ruling
(1) The article does not identify or specify individual Muslims
Defamation, which includes libel and slander, means the offense of injuring a person’s character, fame, or reputation through false and malicious statements. But quoting Newsweek, the subject must be, to a certain extent, identifiable enough with no separate and distinct reputation in the community, which is sufficient to make him stand as a party who will be injured (or benefitted) by the judgment in the case.
In the present case, there was no fairly identifiable person who was allegedly injured by the Bulgar article.
Not a party-in-interest because→Muslims don’t have a single common reputation. Each individual is distinct.
There is no target. Since there is no target, how can a party fulfill the definition of a real party in interest because it cannot be shown that they can benefit or be injured by the judgment?
An individual Muslim has a reputation that is personal, separate and distinct in the community. Each Muslim… belongs to different trade and profession. Together, the Muslims do not have a single common reputation that will give them a common or general interest in the subject matter of the controversy.
One guiding principle of group libel is that defamation of a large group does not give rise to a cause of action on the part of an individual unless→it can be shown that the individual is the target of the defamatory matter. – Arcand v. The Evening Call Publishing Company
The California Court stressed that the aim of the law on defamation was to protect→individuals.
If the subject of an allegedly libelous statement is a very large group, it is considered to have no application to a particular person, since one might as well defame all mankind.
In the instant case, the Muslim community is too vast as to readily ascertain who among the Muslims were particularly defamed.
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